Boyle threatened to "f***ing headbutt" the girl but instead grabbed and pulled her hair.

"The victim stood up and again the accused pulled the victim's hair with her right hand to the aisle and with her left hand slapped the victim to the left side of her face," court documents state.

Boyle left her victim in tears and went to watch a rugby league match, where she continued drinking.

A few hours later, Boyle boarded a full bus at Blacktown interchange and again unloaded, this time directing her hateful remarks at people of African and Pacific Islander appearance.

"F***ing get them. Look what they have done to me, the African c***s," she said to police aboard the bus.

They warned her three times about offensive language but this only fired Boyle up.

"F*** off. I am not being offensive. You want to see offensive? I'll give you offensive. I'll go f***ing smash the black c*** while you're here," she said.

She was arrested and placed in the back of a paddy wagon, from where she continued to yell abuse.

Boyle last November pleaded guilty to assault and using offensive language in a public place.

During a sentence hearing at Burwood Local Court on Tuesday, defence lawyers Michael Moussa and Michael Fantin said the train rant wasn't racially motivated.

They argued it was the result of "an escalated confrontation," but Magistrate Alex Mijovich rejected that.

"You seem to be covering all nationalities in your comments," he said.

Mr Mijovich said people should be able to travel safely and sentenced Boyle to a minimum three months in jail.

Her lawyers had asked for a good behaviour bond, but the court heard she had previously been given bonds and suspended sentences for similar offences, committed during her 15-year interaction with the NSW justice system.

Before being led into the dock and away to jail, Boyle kissed her boyfriend, who had supported her in court.

She was given a maximum 12-month sentence and will first be eligible for release on July 11.